USAco, a domestic corporation, operates a branch in foreign country F. Under country F tax laws, taxable income equals the gross receipts derived from sources within country F, reduced by deductions for significant costs and expenses incurred to produce the gross receipts. However, interest expense is not deductible in computing taxable income. The tax that country F imposes:

(a) may be creditable because the tax passes the net income test

(b) is not creditable because the tax does not pass the the net income test

(c) is not creditable

(d) is creditable